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LEMAY BLDG. CORP. v. DIRECTOR OF REVENUE

No. 76731.

889 S.W.2d 835 (1994)

LEMAY BUILDING CORPORATION, Appellant, v. DIRECTOR OF REVENUE, Respondent.

Supreme Court of Missouri, En Banc.

Rehearing Denied January 24, 1995.

Attorney(s) appearing for the Case

Terrence F. Moffitt, St. Louis, for appellant.

Jeremiah W. (Jay) Nixon, Atty. Gen., Evan J. Buchheim, Asst. Atty. Gen., Jefferson City, for respondent.

PRICE, Judge.

Lemay Building Corporation (Lemay) contests the Administrative Hearing Commission's decision holding that income received from a mobile home park Lemay owns in Florida is income earned partly within and partly without Missouri, pursuant to § 143.451, RSMo Supp.1988. Instead, Lemay asserts the income should be treated as earned wholly within Florida and wholly without Missouri. Because Lemay took sufficient part in the production of income from the...

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